Physicians working in private health institutions are facing significant legal and financial uncertainty as the Turkish government moves to rectify years of irregular employment practices. For over a decade, many doctors have been forced into artificial work arrangements that bypassed standard employment contracts, stripping them of fundamental labor rights.
The Rise of “Artificial” Employment Models
According to reports, some private health providers avoided traditional employment contracts by forcing physicians to open non-existent clinics or establish companies. These arrangements were then framed as “service procurement” agreements rather than standard employment.
This maneuver allowed employers to evade paying essential benefits, including severance pay, notice pay, and paid annual leave. Doctors also lost out on overtime and night shift payments, as well as holiday pay for national and general holidays.
Beyond direct payments, these structures removed critical social protections. Physicians lost access to unemployment insurance and the full social security premiums that affect retirement pensions, while also losing rights to occupational safety and reinstatement after termination.
Regulatory Shifts and the 2025 Mandate
In a move to address these discrepancies, regulatory changes were implemented in 2025. Amendments to Article 12 of Law No. 1219 now specify that physicians will work under the scope of Law No. 5510, Article 4, Paragraph 1, Clause (a).
A critical new restriction has also been introduced: physicians are now permitted to work in a maximum of two health institutions. This follows a period where physicians, despite being dependent employees, were incorrectly categorized as “self-employed” under tax legislation.
Tensions Ahead of the June 1 Deadline
With a transition deadline of June 1 approaching, concerns are mounting over the lack of guidance for employers. Communications from the Ministry of Health and the Ministry of Treasury and Finance have reportedly focused on physicians, while omitting specific obligations for the health institutions themselves.
The Turkish Medical Association (TTB) and various medical chambers have noted a lack of consistency in how these rules are applied. Even physicians in the same specialty and role are finding themselves under different statuses or applications.
Reports suggest that provincial health directorates have struggled to provide satisfactory answers to physicians. Instead, Notice concerns that inspections are being used to “punish” doctors rather than resolve the systemic status issues.
Potential Next Steps
As the transition continues, the Ministry of Health could be required to provide more comprehensive guidance to ensure physicians do not suffer further losses. There may be a push for more synchronized communication between the Ministry of Health and the Ministry of Treasury and Finance to align tax and social security statuses.
Frequently Asked Questions
What specific labor rights were denied to physicians under the “service procurement” models?
Physicians lost access to severance pay, notice pay, annual paid leave, overtime/night shift fees, and holiday pay, as well as unemployment insurance and occupational safety protections.
What is the new limit on where physicians can work?
Under the 2025 regulations, physicians are restricted to working in a maximum of two health institutions.
Who is the primary authority for physicians seeking clarity on these changes?
The Ministry of Health is the primary entity responsible for addressing physicians’ questions regarding the new period.
Do you believe the current regulatory transition provides enough protection for healthcare professionals?
